Handling Government and External Inquiries Guideline

Purpose

To give every employee a clear, simple script for handling an unexpected visit or call from a government investigator, outside attorney, court, or advocacy-group representative — so the Company responds consistently, protects its legal position, and routes the matter to the right people quickly.

Scope

Applies to any employee who is approached, in person or by phone, by:

• A government agency investigator or auditor
• An outside attorney
• A court or process server
• A representative of an advocacy or special-interest group

This does not change any specific regulatory-inspection procedure the Company has adopted for a particular agency (for example, a documented food-safety or workplace-safety inspection protocol) — follow that specific procedure where one exists.

What to do — step by step

1. Record the basics. Get the visitor's or caller's name, title, and the agency, firm, or organization they represent, along with a phone number and address.
2. If in person, ask to see credentials and note what you're shown.
3. Do not discuss the matter further, and do not sign anything.
4. Notify your manager and HR immediately.
5. Tell the visitor or caller that you're referring the matter to HR (or another designated contact) and that someone will follow up.
6. HR notifies Legal immediately, along with any other function that needs to be involved, to determine what response (if any) is appropriate.

If the matter involves a possible criminal investigation

Do not respond to questions until Legal has advised you of your options, which may include responding, declining to respond, or responding only with counsel present. An employee questioned by a government investigator or law enforcement generally has the right to decline to answer questions and to consult an attorney (including having counsel present) before or during any such interview — this is a personal right the employee may exercise regardless of whether Company counsel is also involved, and it is separate from, and broader than, any employer-side representation right that may apply to internal disciplinary interviews.

Responsibilities

Role	Responsibilities
Any employee contacted	Follow the steps above; do not engage substantively or sign documents without guidance.
Manager	Support the employee; escalate to HR without delay.
HR	Serve as the intake point; loop in Legal immediately.
Legal	Determine and coordinate the Company's response; advise the employee of their options.

References

• News Media Relations policy
• Outside Legal Counsel policy